While this regulation is intended to fulfill a US obligation under the IATTC/Antigua Convention, Section 955(c) of the Tuna Convention Act should be set forth which part reads: "The Secretary of Commerce shall suspend at any time the application
of any such regulations when, after consultation with the Secretary of State and the United States Commissioners, he determines that foreign fishing operations in the regulatory area are such as to constitute a serious threat to the achievement of the objectives of he commission's recommendations."
This is particularly important in the case of Pacific Bluefin Tuna since it has been clearly demonstrated that the US catch is insignificant and does not contribute to any overfishing which may be occurring. The fisheries of Mexico and Japan are the predominant fisheries in the North Pacific for Bluefin tuna. It should be noted that the WCPFC Resolution is fatally flawed since it exempts the Japanese artisanal fleet (which we believe is a major source of the overfishing of immature Bluefin), and so far exempts the Korean fleet also, which the Japanese say is taking small Bluefin. The source of the problem with North Pacific Bluefin is not in the ETP, nor due to the Mexican fishery, but rather due to the Japanese take of 0-1 year old fish.
Thank you for allowing me the opportunity to comment on this regulation, Sincerely, Peter H. Flournoy
Comment from PETER FLOURNOY
This is comment on Proposed Rule
International Fisheries: Pacific Tuna Fisheries; Fishing Restrictions in the Eastern Pacific Ocean
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